Regulators impose $350 million fine on American Express for decade-long AML failures

Key points

• The OCC fined American Express National Bank $350 million for failing to maintain adequate safeguards to detect and report suspicious transactions.
• Regulators identified approximately $13 billion in suspected trade-based money laundering activity that was inadequately monitored over an 11-year period.
• The Federal Reserve issued a cease-and-desist order to American Express and its travel-related services subsidiary, citing enterprise-wide AML program failures.
• American Express National Bank must submit a compliance action plan within 90 days and engage a third party for a suspicious activity review look-back.
• American Express CEO Stephen Squeri stated the company is addressing regulator concerns and that the penalty does not impact full-year 2026 financial guidance.

Background

This penalty is the first civil money penalty imposed by the OCC on a bank since a $450 million fine against TD Bank in October 2024, which was also related to Bank Secrecy Act and anti-money laundering issues. Recent regulatory actions, such as the US Treasury's designation of the Russian fintech A7 as a transnational criminal organization in October 2026, highlight heightened scrutiny on financial institutions' roles in facilitating illicit cross-border flows and sanctions evasion.

How outlets are covering it

Yahoo Finance reported the $350 million penalty and the $13 billion in unmonitored activity, noting a slight premarket drop in American Express shares. Banking Dive provided additional detail, specifying that the OCC and Federal Reserve acted concurrently, with the Fed issuing a cease-and-desist to the parent company and travel arm. Banking Dive also highlighted that the OCC criticized the bank for focusing too narrowly on demand deposit accounts rather than its dominant credit and charge card products. A former Justice Department trial attorney, Michael Padula, emphasized that the core issue was the failure to report $13 billion in activity, describing the compliance program as 'wholly inadequate.'

Why it matters

The enforcement action signals strict regulatory scrutiny of anti-money laundering compliance among major financial institutions. The requirement for a 90-day action plan and third-party review indicates that regulators expect immediate structural changes to risk assessment and suspicious activity monitoring processes at large banks.

What to watch

American Express National Bank must submit a detailed action plan to the OCC within 90 days to address compliance deficiencies. The company must also develop an effective risk assessment process and engage a third party to conduct a look-back review of suspicious activity reports. The Federal Reserve expects a plan to improve enterprise-wide compliance risk management.